The market appeal of regulatory endorsements for controversailofferings - evidence from the poker industry.

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THE MARKET APPEAL OF REGULATORY

ENDORSEMENTS FOR CONTROVERSIAL OFFERINGS

– EVIDENCE FROM THE POKER INDUSTRY

Amsterdam Business School Master of Business Administration

Author: Ksenia Chernikova (ID: 10442987)

Academic Advisor: Professor Dr. Jean Johnson, Strategy and Marketing dept.

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Imagine an activity in which hundreds of thousands of people participate every year. A high degree of skill is needed to excel at the activity, but most participants do not possess or develop the skill. Rather, most pursue it as a recreation because they find the activity

pleasurable. Often, they undertake it with friends or in informal groups. A limited number of participants invest substantial resources to acquire the skill necessary for success at the activity. Some of these individuals aspire to earn professional livelihoods from their participation. The very small fraction who succeed as professionals are exceptionally skilled and earn very

substantial sums from the activity. These few participants become famous for their extraordinary skill, and a large portion of their incomes come from the thousands of amateurs who pay sizable amounts to watch the highly skilled engage in the activity.

Many activities fit this description. Musical performance is an example. Perhaps the best example is sports. Millions of young people play sports in casual games, at schools and

universities, or in amateur leagues. Only those with the most extraordinary talents ever play as professionals.

The law regulates each of these activities in various ways, but it generally does not directly prohibit people from participating in the activities. An exception is the activity of poker.

Steven D. Levitt, Thomas J. Miles, and Andrew M. Rosenfield

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Executive summary

This paper investigates the market appeal of third-party organization regulatory endorsements as applied to offerings with a high level of ambiguity. Controversial offerings imply inherent risk for the consumer and this study considers the implied effects of regulatory endorsement on the perceptions of market participants.

Previous academic literature includes discussion of implied effects of a third-party organization endorsement, differentiates between regulatory and public endorsement and supplies theories about the persuasion effects together with factors affecting public perception and attitude

towards endorsed offering. However these studies typically focus on industries or offerings with low ambiguity and perceived risk.

Gambling and poker specifically represents a unique opportunity for a case study. The industry has only been established a relatively short time and lacks critical mass of public acceptance partially due to insufficient public awareness of the role of regulating attempts in the industry. Poker is on the verge of a transformation as more jurisdictions allow this form of activity and participation has grown significantly in recent years.

Qualitative data received through interviews with industry players supports the theory that TPO endorsement effect can be beneficial, but is dependent on a variety of factors. The TPO must be perceived as trustworthy, credible, and an expert source of evaluative information. Maintaining a reputation for quality and assurance of standards is vital in affecting public opinion change. Depending on the level of market competitiveness, TPO endorsement could be seen as a differentiator and can be leveraged with marketing activities of endorsed venue. Endorsements for controversial offerings specifically may contribute to enhanced perceptions of legitimacy as these markets continue to develop.

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CHAPTER I

Introduction

TPO in general

International non-governmental organizations, professional associations and third-party organizations operating individually and collectively can have an impact on many aspects of people’s lives, including their social rights and opportunities. Their purpose is to represent themselves as a provider of evaluative information regarding industry standards and quality policies. TPOs can be nonprofit or for profit, governmental and non-governmental organizations. The role of TPOs among the industries may differ depending on the how advanced the industry has developed from a regulatory perspective. TPOs may operate as mediators between businesses and the public, building public awareness, providing information and educating the public about quality standards for an offering of a given type.

TPO endorsements in general

Third-party organization (TPO) endorsements are aimed to ensure quality within an offering of a given type. Following on from that objective, goals include standardization, creating legal and social precedence and creating and maintaining support for growth of the industry and business opportunities.

Endorsements are distinguished as either regulatory or public; regulatory endorsement implies conformity to strict standards verified by industry regulators while public endorsement

represents a public acceptance in general. There are several types of endorsers identified:

celebrity, expert and typical customer evaluations rely on the perceived credibility of the source, whether it represents an expert view and whether the source is seen as trustworthy. TPO

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endorsement may be seen as a source of competitive advantage among competitors since it could be seen as a differentiator in a crowded marketplace and may affect public perceptions towards the product offering.

Controversial offerings in general

Ethically controversial offerings cover a range of product or service offerings of which statuses are not globally unified, since historical and contemporary moral and ethical aspects depend on a subjective norm. (Interpretation of the state law, national regulations, personal beliefs etc.). Examples of ethically controversial offerings include, but are not limited to, gambling, marijuana, and genetically modified foods.

Poker represents a comprehensive case within the gambling industry itself since it could be argued that it is placed in this group of ethically controversial offerings by choice, insofar as its position not only depends on the legislative perspective of the industry, political environment and the effectiveness of the third-party commercial or non-profit organizations, but also the

understanding of whether the activity should be considered gambling in itself. Poker involves an element of skill as well as elements of chance, and it has been argued that this activity should not be considered as gambling at all. The poker industry is currently on the verge of a structural transformation. FIDPA is focusing on standardization through the establishment and spread of regulated procedures and its goal is to bring consistency and unified standards to the industry. Markets around the world are beginning to liberalize their position on poker and the gambling industry, and over the last decade there has been an unprecedented growth in participants of poker worldwide. Poker events and tournaments attract participants from beyond national borders, lending importance to use of standardized rules and regulations across jurisdictions.

Another case of a controversial offering is genetically modified crops and other genetically modified organisms used for food production. Depending on the legislation, some countries enforce labeling policies, countries of the European Union, for example, some countries have partially enforced or non-enforced labeling policies like Brazil and Chile, but there are also

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countries like United States and Canada with no labeling required. The question of labeling is a point of a public discussion. Public interest is in getting informed whether or not food contains GM organisms and its potential harmful effects on health. Nevertheless, varying interests of manufacturers, consumers, governments and third-party organizations often conflict with the consumer’s right to get information from an independent source (Raab and Grobe, 2003). Regulatory bases in different countries vary because of different methods for risk assessment towards GMO in food production. According to the public sentiment about genetically modified food by Pew Initiative on Food and Biotechnology (2001: 3) it is suggested that ‘Americans want to know whether their foods have been genetically altered. Seventy-five percent (75%) of Americans say it is important to them to know whether a product contains genetically modified ingredients, with 46% saying it is very important. Only 21% of consumers say that it is not important for them to know whether a product has been genetically modified.’ It is suggested by Gruère and Rao (2007) that countries regulate the labeling because ‘consumers should be informed of the novel traits and properties of the food products in order to make informed decisions.’ (Gruère, Rao, 2007, p. 52).

TPO endorsement of controversial offerings

Controversial offerings involve an element of inherent risk. In the poker industry, the consumer has inherent financial risk when participating in an event, and in unregulated situations may also be at risk from a safety perspective. These factors speak to the vulnerability of the offering, and to the high level of personal involvement as perceived by the customer. In order to be effective TPO endorsement must be seen as a seal of approval, a guarantee of certain conditions to be met. This may reduce the ambiguity factor as perceived by the customer and contributes to their decision to act. The ability of TPO endorsement to affect change in the receivers opinion is based upon the persuasion effect. As the endorsement aligns with the customers value system they may be more receptive to messages closer to their own opinion.

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The role of TPO in endorsing controversial offering is to reduce the level of perceived risk by customers, through introduction of industry standards, and giving out an endorsement to market players if they comply with the regulations and are willing to get approved by a TPO. Promoting a set of regulations as the industry standard is proposed to enhance consistency across market players, and ensure customers familiarity with the role of regulation and the regulation itself. That in turn could be considered as a step forward towards global legitimization of the controversial offering. TPO endorsement could be employed in the advertising campaigns of market players and used to infer messages about the venue’s quality and safety standards.

Having an independent source providing evaluative information about the quality standards of an offering could be valuable to both the consumers and market players as providing a set of

regulations is aimed at increasing industry standards and global participation. This study focuses on the value of the endorsement for controversial offering in terms of market response.

Research context - gambling and poker as controversial offering

From a regulatory perspective poker is considered gambling as it comprises three elements: consideration, chance and prize. It is offered mainly by casinos along with other chance-based games, however, it is also played online, in small poker clubs and at home both among amateurs and professionals. Outside of large casinos, quality and adherence to regulations may be less stringent. By engaging in a poker game, the participant risks losing a financial stake, but also gains the potential to increase their winnings. In cases where the participant is not fully aware of the rules situations may arise where disagreement occurs based upon inconsistencies in play. This gives rise to the risk of unfair treatment. Large variances between rules used by different operators may lead to confusion among participants, and in this respect the existence of formal standardized rules and quality assurance may be valuable in reducing inherent risk.

Due to the ambiguous status of this offering, there exists a grey area in the poker industry with increased risks implied. This study will focus primarily on the implied effect of regulations on the legal side of poker market. Although this study does not cover the implied effects on grey

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area within poker industry, it could be argued that TPO endorsement can contribute not only to the legitimization of the product offering, but also to diminishing the effects of grey area presence in the gambling and poker industry.

A qualitative methodology was used in this study as poker represents a case with unique

qualities. This case deals with the emergence of regulations in a developing market in addition to endorsement being a signal of quality for a controversial offering. Interviewees were selected on the basis of perceived relevance in regard to market perception of the TPO endorsement, and in order to cover a broad cross section of industry participants. The studies examined the opinions of different industry players: poker federation, casino holding monopoly, casino in competitive market, media, pool of professional poker players and a tournament director.

TPO endorsement of gambling/poker

Game providers may use any set of house rules, however, there are several widely used sets of rules: IPR (International Poker Rules) by FIDPA (Federation Internationale de Poker

Association), TDA rules (Tournament Directors Association), rules used for WSOP (World Series of Poker) and rules provided by Pokerstars for the EPT (European Poker Tour) for hosting international events. FIDPA and TDA are both providing official endorsements of compliance with a set of policies regarding overall quality of the offering.

TPO Endorsement for poker provider is proposed to ensure professionalism and quality

standards, fair treatment and adherence to the rules. Logos can be used for a variety of marketing purposes, advertisements and publicity to enhance brand awareness of a venue. The rules cover game policies and behaviour of staff in ambiguous situations. The endorsement implies

compliance with rules as well as assurance that the game provider has the necessary facilities and competence level of staff required for a high standard of offering.

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In order to test the market attractiveness of FIDPA as a TPO endorser within the poker industry, a variety of market players were asked for their opinions and perceptions of FIDPA’s endorsement. Specific characteristics including credibility, trustworthiness and expertise were discussed with the interviewees in order to gauge their perception of FIDPA as a reliable source of independent evaluative information. Data was collected on the impact of endorsement on perceived

qualitative and risk related characteristics of endorsed product offering from various market players.

Description of how the rest of the thesis proceeds

There follows first an overview of literature. The selection of academic papers was made in order to cover a broad range of literature, as recommended as part of a qualitative methodology of conducting research. Secondly, a case study is presented about FIDPA’s place in the poker industry. Thirdly, a discussion of the methodical approach is provided in order to support the choice made by the author in collecting data. Fourthly, the findings of interviews are presented with respect to the market appeal from customer, business and industry perspectives. Finally, theories derived from the review of literature and interview results are considered in relation to the poker industry, and, through generalization, to a wider market scope.

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CHAPTER II

Review of literature

Introduction to the literature

Literary theory on this subject suggests that public perception of the endorsement relies on source credibility, which in turn is affected by the perceived trustworthiness, expertise and attractiveness of the TPO. Information asymmetry and access to evaluative services are also found to be influencers in the effectiveness of TPO endorsements, as when consumers do not have the resources to independently evaluate every offering of a given type they may benefit from independent evaluation by a third party.

It was found that consumers are attracted to signals about a company’s quality. Further research has been carried out from a commercial perspective about how those signals affect purchasing intention, perceived risk and consumer’s perceptions associated with an offering, and the uniqueness of the endorsed product offering. Researchers differentiate between public and regulatory endorsements, and the process by which the offering is accepted as congruent with the consumer’s value system. It was found that level of personal involvement affects the probability of engaging in an action.

Researchers found trustworthiness and expertise as catalysts for opinion change which in turn may result in public acceptance. Lack of acceptance may derive from lack of trust. Gaining public trust through a TPO endorsement that the offering is put forward in accordance with local laws and industry regulations may lead to perceptions of legitimacy of controversial offering of a given type. Increasing public awareness of industry standards may lead to further public

acceptance. Once public acceptance has reached a critical mass, the offering may be on the verge of gaining a legitimate status worldwide.

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Implied effects of endorsement

‘The TPO endorsement is defined as an advertisement that contains a positive evaluation of the advertised product or service that comes from an identified third-party organization’. According to Feng et al (2008), there is an information asymmetry between buyer and a seller and only a seller knows the real product descriptors in terms of quality. Boulding and Kirmani (1993), Kirmani and Rao (2000) and Feng et al (2008) investigates the sender and receiver relationships when communicating to customer. According to Feng et al (2008) in order to evaluate quality of product offering, it was suggested that consumers require additional credible information. Information asymmetry is especially critical in the assessment of the implied effects of TPO endorsement as signaling unobservable product quality. However, it was found by Wang (2005) that trust and perceived risk are affected by believability of the TPO endorsement for a product offering. Moreover, studies revealed that customers’ purchase intention depends on level of trust and perceived risk among consumers towards the TPO endorsement.

Studies of Grunig and Grunig (2000) suggest that consumers may prefer to receive information from other sources, personally from a company representative or from the internet. Consumers attend to signals about a company’s quality, as do shareholders and competitors, although it would seem that the company’s reputation is not as relevant to consumers as the value of the particular product itself (Dunham, 2011). When consumers do not have access and facilities to get evaluative information regarding the product, they seek to get an external opinion. According to Dowling and Staelin (1994) and West and Broniarczyk (1998), consumers digest external opinions in order to evaluate a product offering and make a purchase decision based on the perceived risk and trustworthiness of the information sources. It is more likely that TPOs are seen as possessing sufficient resources to test and evaluate than individual experts (Feng et al, 2008). In the case of GM food, it is impossible for the consumer to evaluate whether a product contains GMO or not, and the high cost of funding research makes it unlikely that consumers can

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gain access to information regarding health effects of consuming GMO. According to a survey conducted by Public Pew Initiative on Food and Biotechnology (2001: 3), the public remains ‘extremely supportive of continued research into GM foods and look toward the regulatory agencies to provide them with accurate and trustworthy information.’

One could argue that there is a substantial difference between a group of ethically questionable offerings and the ones with lower risk involved, this difference makes it important to provide the customer with the explicit information about such ambiguous offerings. Several researchers have investigated the consequences of a third-party organization endorsement (Dean and Biswas, 2001, Feng et. al, 2008). The studies suggest that TPO providing evaluation of the product based on experience characteristics may provide enough qualitative information in regard of the product offering that it will reduce consumer uncertainty and the risk perceptions (Dean and Biswas, 2001). Some researchers also studied implied effects of TPO endorsement in advertising. It was found by Kamins (1989) that celebrity endorsements can make advertising more credible and increase customers’ brand awareness. Studies of Ohanian (1991) and Kable and Homer (1985) investigated the likelihood of endorsement positively affecting customer’s purchase decision. Studies of Dean (1999) revealed that a customer's perception of product quality and its uniqueness is affected by TPO endorsement and it also suggested that TPO endorsement

included in advertising might strengthen a consumer’s perception of endorsed offerings. However, studies of Peterson, Wilson and Brown (1992) revealed no TPO endorsement effects applied to print ads containing TPO endorsement comparing to ads without a TPO endorsement.

Several researchers investigated source credibility and its dimensions. Some supported trustworthiness as the most important dimension of credibility and that propose that it can contribute to persuasion effect (Kamins 1989; McGinnis and Ward 1980), other researchers found that expertise has this status (Ohanian 1991; Swartz 1984). Research has found that credibility would more likely affect persuasion of a TPO message rather than the perceived attractiveness to the viewer (Dean and Biswas, 2001). Depending on both expertise and

trustworthiness towards TPO, its endorsement can signal quality and inform the public (Feng et al).Different types of endorsers were distinguished: expert, celebrity and typical customers

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endorsements as well as examining the potential behavior of the different social actors within the endorsement procedure (Kelman 1961; Woodside and Davenport 1974; Freiden 1984; Friedman and Friedman 1979). Additionally, studies of McGinnis and Ward find that an expert who was perceived as trustworthy agent generated the most significant opinion change (McGinnis and Ward 1980).

Public opinion change

Public opinion change is related to acceptance of an activity previously seen as rather ethically questionable. Studies of Deephouse (1996: 1025) differentiate regulatory and public acceptance. Studies suggest that regulatory endorsement is ‘the acceptance of an organization by the state agencies that formally regulate it. Public endorsement is the acceptance of an organization by the general public.’ Consumers’ beliefs about the positive characteristics of an offering may be enhanced through reputation advertising. (Dasgupta, 1998) where a third party organization lends its reputation to an endorsed venue.

Changing in underlying beliefs is leading to public acceptance (Kelman, 1961). Another studies of Kelman (1958) differentiated three stages of opinion change called compliance, identification and internalization. Compliance occurs when a social actor may feel uncomfortable about decision made as it is not aligned with actor’s value system. Identification is proposed to be an acceptance of induced behavior without further questioning. Among the others processes of social influence Kelman identifies a stage of internalization. It occurs when an ‘individual accepts influence because the induced behavior is congruent with his value system’(Kelman, 1961: 65). It is claimed by Pallak (1972) that messages closer to one’s own position

(proattitudial) were assimilated and, therefore, more acceptable than contrasting messages. Studies of Sherif (1973) postulate that degree of involvement is related to judged credibility: the higher level of involvement of public is, the more importance credibility has for it. The studies of Petty and Cacioppo on the elaboration likelihood model (ELM) of persuasion suggests that personal relevance variable is considered as the most valuable for further message elaboration. Studies also suggest that as personal relevance increases, people become more motivated to

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process the issue-relevant arguments presented. (Petty & Cacioppo, 1986). According to Petty and Caciappo (1979: 1924), ‘nonmessage cues such as expertise or attractiveness of a source should have maximal impact when ... message is on a topic of low involvement’ while the message content should have maximal impact under high involvement conditions’.

There are three types of endorsers identified: expert, celebrity spokesperson, and typical consumer (Friedman and Friedman 1979). Studies of Kelman (1961) also propose that expert endorsers influence through the process of internalization. If endorsement is perceived as a seal of approval that a controversial offering is presented in accordance with strict regulations and system of standards could lead to alignment with their value system and therefore may lead to opinion change during the internalization phase (Kelman, 1961: 65).

Legitimacy through regulations

Controversial offering with a certain risk involved represents a moral hazard for the consumer with immediate financial impact. In case perceived risk associated with consumers’ purchase decisions increases, consumers are more likely to seek out the opinions of others for evaluating products (West and Broniarczyk, 1998). Controversial offerings require consumer to take inherent risk and in these instances endorsement can also signal legitimacy. In ethically

ambiguous offerings where consumers benefit from some form of guarantee or assurance that if you take engage in action, certain conditions should be met. Certification leads to unified standards and reduces risk of fraudulent practices (Montecalvo, 2001). Controversial offerings may have higher risk of fraud than other industries, therefore endorsement or certification as a regulated controversial offering could be more attractive to potential customers as this allows them to minimize their inherent risks. According to Colorado Limited Gaming Act ‘Public confidence and trust can be maintained only by strict regulation of all persons, locations, practices, associations and activities related to the operation of licensed gaming establishments and the manufacture or distribution of gaming devices and equipment.’ (Colorado Limited Gaming Act, 2012, 12-47.1-102).

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Legitimacy comes if a product offering is exactly as proposed, accordant with law or with established legal forms and requirements, conforming to recognized principles or accepted rules and standards as defined in the Merriam-Webster dictionary. When consumers are aware of their rights and the standards which should be met then the offering is better understood and

potentially more accepted. According to studies of Deephouse (1996: 1025) legitimacy could be conceptualized as both a process and a state and from ‘evaluating perspective signifying

desirability and normativity, or from a cognitive perspective signifying understability and taken-for-grantedness’.

It was shown by studies of Deephouse (1996) that there is a positive relationship between strategic isomorphism and legitimacy. Strategic isomorphism is defined as the similarity of a focal organization's strategy to the strategies of other organizations in its industry. It is also suggested that organizations create norms of social behavior in alignment with external demands, and that in a competitive market players will imitate successful organizational behavior and that may lead to assimilation of the strategies of venues with a product offering of a given type. Studies of Meyer and Rowan (1977) suggest that organizations pursuing unique strategies suffer in terms of legitimacy because it could be perceived unacceptable by external actions.

In case of regulated industry standards, as one of the key objectives of governing TPOs, the interorganizational perspective should be considered. If an independent organization controls at least some of the activities of a venue, that implies the issue of external control acceptance by the venue. Pfeffer and Salanik (1978) provide interesting insights into organizational behavior and interorganizational influence or social control. Those processes are explained to be affected by interdependence which exists when one actor does not fully control all of the conditions necessary for the action. Pfeffer and Salancik derived the list of conditions which increase the probability of success of external controls. If an organization’s actions are visible, if it desires to survive, if management is aware of external demands, and it has sufficient facilities to develop the actions to satisfy these demands, then these criteria are suggested by authors as affecting the likelihood of external control being accepted. Even so, acceptance of external control may imply additional costs incurred to ensure compliance with standards and regulations such as additional

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staff training or additional facilities to be provided.

Not all the controversial offerings are the same, they may vary on the level of perceived risks involved, therefore, the more ambiguity that exists, the more work needs to be done to make a regulating attempt visible and desirable to the industry players. The research of consumer attitudes towards genetically modified food and its labeling by Carolyn Raab and Deana Grobe (2003: 160) revealed that ‘increased consumer awareness ... could influence future support for labeling’. Therefore, educating the public about the role of rules and regulations for controversial offerings could lead to increasing customer awareness about the quality standards in the industry.

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CHAPTER III

Case Study

About FIDPA

Located on Malta, FIDPA is an international third-party regulatory organization in the poker industry encouraging card rooms and tournament organizers to operate at the highest level of standards. FIDPA has a growing partner network of endorsed venues, leagues and federations in such countries as Australia, Belgium, Mexico, India, Poland, USA, England etc. It strives to maintain, promote and implement the international poker rules as the standard in the industry. International poker rules represent an extended version of all the other existing rules, in particular it fully overlap the rules offered by TDA (Tournament Directors Association). It is proposed to be an industry standard and even though that could only happen if other

organizations will support IPR (International poker rules) as a standard. FIDPA is controlled by Marcel Luske, a professional poker player, under the assistance of legislative, administrative and executive professionals.

FIDPA as a TPO

The first attempts to regulate the poker industry were made in 2002 after a so-called poker boom; such organizations as EPPA (European Poker Players Association), TDA (Tournament Directors Association), IPF (International Poker Federation) emerged to increase the awareness of the game and increase participation on the global level. It eventually emerged as FIDPA (The Federation Internationale de Poker Association). By that time the problem of inconsistency within the world rules and basic poker procedures was less evident, it took about 10 years to create a group of international professionals in the poker industry who value professionalism and who contribute to the game and industry development by supporting the highest standards. The

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question is whether the number of such people is already sufficient enough for moving the industry standards up.

FIDPA’s vision is in taking an active role to ensure the integrity, fairness and a level of standards for the industry and the players. It is envisioned that FIDPA serves as a source of increasing awareness, education and communication among legal card rooms, poker tours, leagues,

tournaments, industry associations, organizations and federations. By providing knowledge and support about poker rules and regulations, it is proposed to provide the most professional, player-friendly service to players and environment to play in. FIDPA allows anyone to use the rules for professional or private use, regardless of whether it is a private poker player or hosting a poker event in a casino or a poker club.

The main activity of FIDPA is in giving out official endorsements based on the international poker rules and listed procedures. The procedure of giving out the endorsement consists of several stages of checking overall service quality, necessary facilities, qualification of staff to ensure the quality of the endorsement, since reputation is considered as the most important value a TPO can possess (Feng et. al, 2008). If all the requirements are met, the venue receives an official endorsement which it is free to use in advertisements, logos and on any attributes during the event.

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CHAPTER IV

Methodology

The chosen methodology for this research is the use of case studies to provide description, test theory or generate further theory. This approach was considered by Eisenhardt (1989) who suggested that this methodology allows the researcher to focus on understanding the dynamics within a given setting. This research will cover multiple case studies with various industry players and interested parties. It will generate only qualitative data, which will be used to test the theory of market attractiveness of TPO regulatory endorsement for controversial offerings.

As discussed by Eisenhardt (1989), the methodology begins with the formulation of research questions. In this case the focus is on the market appeal of TPO regulatory endorsement for controversial offerings, specifically focusing on the poker industry. Deliberate theoretical sampling was used to select the cases, whereby individuals were selected with the intention of representing a cross section of industry players and stakeholders. This allowed the researcher to focus on those cases which were considered most theoretically useful to the studies, and to remain theoretically flexible.

Information gathered through interviews was analyzed both within case and by seeking to

identify cross case patterns. As part of the research design, multiple data collection methods were used to enable synergistic view of evidence. The methodology used calls for an iterative process between theory and qualitative research. A crucial element of theory building is comparing emergent concepts with existing literature. This study considers a broad range of literature in conjunction with the case study interviews in order to compare results to current theory. By analyzing the results as related to the literature, the internal validity and generalizability of the results can be tested. This approach permits the researcher to leverage emerging themes and

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focus on unique or extreme case features.

Among the strengths of case study research under qualitative methodology Eisenhardt finds that there is a high possibility of generating original research, and that subsequent theory can be tested within the case study framework. As theories generated can be proven false, any theory which emerges from the data is likely to be valid.

However, using qualitative methodology implies several limitations for a researcher. According to Yin (2003), a lack of thorough research may lead to the presentation of vague data or biased perspectives which may influence the outcomes. Additionally, as Eisenhardt (1989: 547) claims, it may result in ‘theory which is rich in detail, but lacks the simplicity of overall perspective’.

Eisenhardt (1989) proposed that the case study research can be considered to have reached closure when the research hits saturation point and there is minimal expected improvement to the theory to be developed from subsequent iterations and further case studies. Table 1 provides additional data about the interviews conducted.

Research data was collected through set of interviews with different market players in terms of their response to the TPO endorsement. The interviews were structured to cover such issues as the poker industry in general, public awareness of quality standards presented across the

industry, implied effects of TPO endorsement, interoperability and business issues. Additionally, data was gathered from the official websites of interviewees, amendment to the constitution state of Colorado article XVIII, Colorado Department of Revenue, Division of Gaming, and public sentiments about the consumer attitudes towards genetically modified food provided by The Mellman Group and Public Opinion Strategies. Table below provides additional information regarding the interviews held.

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Position Organization Location Duration Founder, director The Federation

Internationale de Poker Association

(FIDPA)

Malta 10 hours

Manager public affairs & media relations at Holland

Casino

Holland Casino Netherlands 2 hours

Product specialist table games and

poker, former revenue manager

Holland Casino Netherlands 2 hours

Table games manager

Holland Casino Netherlands 2.5 hours

Customer, professional poker player, champion of the Netherlands 2008, winner of the Main Event of European Poker Tour Former member of Pokerstars professional team, independent social actor Netherlands 2 hours Media representative, senior writer and

live reporter

www.pokernews.nl Netherlands 2 hours

Tournament director, independent expert, former marketing manager in casino Casino de SPA (Circus Casino group) Belgium 1.5 hours

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CHAPTER V

Market appeal

Customer’s perspective

There are several customer segments attracted to poker offerings, these include professional poker players with international appearance at major events, recreational players, tourists and celebrities attending a poker event. Since a casino profits from collecting the rake from poker players, the more money customers stake, the more profitable it is for the hosting venue.

Professional players attract the interest of amateur players both by appearing at poker events and by giving their opinion on industry development. Such celebrity endorsement may allow casinos to attract other international poker players. Marcel Luske regularly appears at major events as an affiliated professional player of Pokerstars team. Being a media persona he often helps to

increase public awareness about the industry standards by communicating to the poker

community via media channels. His ability to contribute in creating awareness is acknowledged through the interviews as well as his status as one of the industry experts.

It is suggested from customer perspective that since a professional poker player aims to minimize risks while increasing profit, a poker room or tournament with the official endorsement could be seen as a signal of quality and higher service standards. From a customer perspective, it can also contribute to their objectives of reducing wasted time resulting from arguments between people who are used to different local rules and regulations or asking floor management about the rules to resolve possible situations under dealer incompetence.

Inconsistency of rules takes place not only in different countries, but also among major events in the poker industry. The interview with the poker pro revealed that the industry currently lacks a standardized set of rules to be used globally. Poker players could benefit from having defined industry standards from several perspectives: operational excellence of the game providers,

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fairness of treatment, game speed and quality of service provided. This benefits customers by decreasing the risks and increasing potential profitability per hour. When a player travels to a foreign country, he may be more likely to choose a venue with the official endorsement as more credible. That is supported by implied effects of a TPO endorsement in the advertisement (Feng et al, 2008). In addition to providing standardized rules, endorsement could also be seen as a solution to the problem of quality, safety and time consumption. That suggestion is supported by studies of Kelman about opinion formation and change: the poker player community seems to be going through a stage of opinion formation called internalization, when influence is accepted by the community because the induced behavior is inherently conductive to the maximization of their values (Kelman, 1961).

Business perspective

Legislation plays an important role for the gambling industry worldwide with significant

variances between jurisdictions. For the purpose of this research two case studies are considered: the Netherlands and Belgium. These cases illustrate the differences which arise from the

industries being in different stages of liberalization with Belgium having poker legalized in 2005 in the private market and the Netherlands holding a state controlled monopoly for casinos in the country.

Monopolistic view

Holland Casino is a monopolist in the Netherlands providing a wide range of chance-based games. Poker is included within this from the regulatory perspective. The management group acknowledges the importance of having rules in house and being consistent with them. However, the qualitative difference between various sets of rules is not perceived as a critical factor to act in favour of standardization of rules on a global level.

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have a unified set of standardized rules in foreseeable future. Most of the sets of rules overlap each other and it is suggested that with any given set of rules, there is still room for different interpretation. Holland Casino uses house rules and the rules provided by a TDA (Tournament Directors Association) when hosting international events.

It is suggested by the management group that customers are often not aware of regulations and rules in house, therefore, a marketing department has to deliver the message to the customers properly, demonstrating what official endorsement really means for them and how they could benefit from it. Marketeers could use TPO endorsement containing message as an effective tool in communicating to certain customer groups. It is suggested that having an official endorsement could also be exploited in building trustworthy relationships with customers. That could help venues to use an official endorsement as a promotional tool to increase their customer base and increase customer loyalty. However, the marketing director of Holland Casino suggested that level of personal relevance will vary among different customer groups. He also pointed out that customer group that will value regulatory endorsement the most is the group of professional poker players with international appearance and the participation in the major events. That is supported by work of Sherig (1973) who postulated that the degree of involvement is related to judged credibility: the higher level of involvement of public is, the more importance credibility has for it.

The rationale for the unwillingness of Holland Casino to gain official endorsement and use it is due to the relatively small proportion of professional players who would be affected by it, as opposed to the other customer groups and their associated familiarity with the topic. Moreover, due to restrictive advertising on poker offerings, the impact of the endorsement when used in the advertising purposes could be limited.

Non-monopolistic view

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flemish, french parts of the country and in Brussels. One of the casinos with the official endorsement by FIDPA is Casino de Spa in Belgium (Circus Casino group).

Casinos are privately owned in Belgium and the poker industry has actively grown since 2008 among Belgian casinos. It is suggested through the interviews that increasing competition is leading to increasing industry standards in terms of quality of service. The Belgian scenario represents a case with active competition for attracting customers, especially when poker industry is on a verge of structural transformation. Finally, in case of active competition on the market, gaining competitive advantage could be achieved by creating an enjoyable atmosphere to comfort clients, increasing safety standards as well as quality of service provided. Additionally, venues need to be innovative with offering new games and organizing special events. However, it was suggested that organization of a poker tournament has significant costs, therefore poker offering is suggested to be considered as a marketing tool since its profit streams are limited due to high Belgian tax rate of 44% of revenues.

Hosting an international event, TV and online broadcasting leads to increasing customer base through increasing publicity of a casino. Having a standardized set of rules allows casinos to maintain reputation since it means that service is provided on the highest industry standard by professional staff. Interview supported that FIDPA’s logos and attributes are used when promoting tournaments.

Operating under regulations by FIDPA is perceived by tournament director as ensuring

consistency with rules and fairness of the game for participants. That contributes to increasing customer satisfaction and customer loyalty. The attempt of operating under regulatory base is perceived as the way to protect interests of players as well as of game providers.

Dunham (2011) suggested that consumers attend to signals about a company’s quality. From a marketing perspective it was proposed that customers are attracted by signals of quality and safety. It was also revealed that if player knows the rules which are being played, it can lead to decreasing customer’s perceived risk and could be one of factors to choose in favor of a venue

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since it assures fairness of treatment. It is also suggested that word of mouth is playing a role in poker community, therefore, reputation of a venue has a significant importance for current and potential customers. Having an official endorsement for a casino could be seen as a source of competitive advantage among competitors. According to Dean and Biswas (2001), TPO endorsement may help marketers with endorsed products in positioning their products against competitors.

Circus casino group claims tournaments are played under the FIDPA rules. That implies

increasing professionalism among employees, so that every dealer and floor employee is aware of rules and being consistent with them. Additionally, it was supported that having the official rules may lead to decreasing time spent on arguments between players and therefore could be profitable for a player while maximizing his values.

Conclusion of case studies

Most European countries are looking to legislate and regulate the poker industry, however, even within the European Union regulations in the domestic markets vary noticeably according to local law, accessibility to the global arena, ways of taxation of the player's income etc. ‘Due to differences between national laws, regulations and the legal state of poker, there are too many obstacles to make the centralization idea for the poker industry really effective', as suggested by the senior writer and live reporter of pokernews.nl.

The two scenarios considered address the impact within competitive and monopolistic markets. Belgium scenario of private market development is suggested through interviews to be a possible template for industry development in the Netherlands when competition is introduced, associated with the license issuance. In this case having an official endorsement by a TPO could be

considered as the first-mover advantage among competitors what is supporting the preposition by Feng et al. that ‘TPO endorsement ads highlight the quality of the advertised product and

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It was suggested that having a source of independent expert opinion is valuable for poker community as proposed by literature. Studies of Feng suggest that reputation, as the most valuable asset that TPO possesses, affects TPO’s ability to influence companies in the market (Feng et al, 2008 ). This is supported through the interviews with the management group of Holland Casino and Casino de Spa, that the stronger the authority of the endorsing body is, the more attractive it is from the business perspective. A similar principle applies with the

competition, the stronger the competition, the more attractive the opportunity to get an official endorsement for businesses.

From the media perspective, there is a considerable way to go in standardizing poker rules and establishing the industry standard. Currently the media focuses on covering major events associated with the biggest industry players and not investigating issues from the grey area perspective. The effect of having regulatory bodies may be undermined due to limited scope of published materials on the source of interview.

There is a certain sense in having a certified set of rules or an official endorsement for venues which are active in hosting major international events. Allowing people to know beforehand which set of rules is going to be used during the tournament seems to benefit all the parties - venue, media and customers. Players often read the tournament press releases, knowing all the details about the rules could be seen as an additional incentive to join the tournament. Media sources would be seen as more credible and it could lead to increasing customers’ time spent on website. The casino releases ads and news containing third-party endorsement, which is

suggested to ‘highlight the quality of the advertised product and distinguish the endorsed product from competitors’ (Feng, 2008: 616).

Perception of TPO endorsement for controversial offerings depends on the level of personal involvement and public awareness of the topic. Petty and Cacioppo (1986) suggested in the elaboration likelihood model on persuasion that there is a correlation between personal relevance and motivation to seek out and process issue relevant arguments. Those for whom there is a high personal relevance are more likely to invest the time and effort needed to fully understand issues

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and risks. It is also claimed in the studies of Raab and Globe about labeling GM food that ‘increased consumer awareness ... could influence future support for labeling’. (Raab and Grobe 2003: 160). Similarly, participants in poker events have an immediate financial stake in the smooth running of the event. Increased awareness of poker regulations in general may give participants additional incentives to compete.

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CHAPTER VI

Conclusions

The status of controversial offerings differs from country to country. The industry is in various stages of legitimization and regulation including the online segment. The environment in which controversial offerings operate impact the level of market attractiveness of the TPO.

Due to the ambiguous nature of controversial offerings, research has found that the availability of a third-party organization endorsement to be beneficial in increasing market appeal of that

offering. Third party must have the resources and capabilities to evaluate offerings and maintain a reputation of quality and assurance of standards.

Furthermore, studies found that quality assurance in controversial offerings is related with safety level associated with an offering of a given type. Therefore, a TPO endorsed venues may be perceived as lower risk than unendorsed alternatives because TPO endorsement implies

operating on the highest industry standards which could reduce suspicion in public mind towards controversial offering and increase its credibility.

In a monopolistic environment the endorsement is having limited appeal due to lack of economic competition. On the one hand, there is no need to differentiate a product offering from that of a competitor, on the other hand, there is lower public awareness of regulations and role of rules among public if marketing is performed by only one market player.

That suggests that in case of a lack of economic competition, the implied effects of official endorsement will only be valued by a limited customer group, therefore they may not be perceived as the effective tool to improve the market appeal of the controversial offering and increase its profitability parameters. Therefore, a marketing department will not be able to exploit its full potential.

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In a competitive environment TPO is seen as more attractive to market players with controversial offerings. It is perceived as a differentiator and is regularly used for events organizations. It was shown that consumers of controversial offerings attend to signals of quality and safety levels associated with the product offering. When customers know in advance the rules under which an event might be held, studies show that it decreases perceived risk and contributes to building trustworthy relationships with customers.

Market attractiveness of regulatory endorsement is linked to the ability of a TPO containing message to reach multiple customer segments as different types of players have different levels of involvement. Increasing customer and public awareness about regulations and the role of regulations on every level may lead to increased effects of TPO endorsement as more people become involved. The ability of a TPO in controversial offering to be perceived as a credible source of evaluative information depends on the trustworthiness and expertise of the source.

Controversial offerings have not yet gained sufficient public acceptance and therefore gaining this acceptance could set a precedent for future legitimization. Another form of acceptance is regulatory acceptance of an organizations by the state agencies that formally regulate it.

The presence of regulatory governing bodies in controversial industries is a step towards legitimacy as this signals the existence of agreed standards and formal regulating actors. To increase market appeal or market attractiveness of regulatory endorsement, TPO must maintain a high reputation and trustworthy relationships with other industry players.

It has been shown that during the internalization phase of public opinion change TPO

endorsement can have an effect of persuading consumers to alter their opinion or their perception of the controversial offering. It has been shown that this persuasion effect is maximized when endorsement is given by an expert who is perceived as a trustworthy agent.

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towards controversial offering since it could be seen as solving potential problems for the social actor regarding safety and quality standards since such kind of offerings imply inherent risk and could be seen as more legitimate.

A regulatory endorsement of TPO obligates venues to operate in accordance with the rules and educate employees about the standards and regulations and minimizing number of situations where decisions are challenged. Endorsement of a TPO used in advertising is perceived by customers as a assurance of reliability of the source of the regulations in place. Increasing customer satisfaction of controversial offering under strict regulations contributes to building trustworthy relationships with customers. If the TPO is highly regarded, then endorsement and regulation of market players may lead to an increase in the potential customer base by ensuring quality and customer loyalty to the venue.

By increasing customer awareness about quality standards, TPO may increase the pool of people for whom it is relevant. From an interorganizational perspective, market players must cede a level of control so that the endorsement and consistency with regulations is tested and verified. As a result, supporting an image of TPO as an accurate and trustworthy actor in the industry is crucial. In order to increase market appeal of regulatory endorsements, TPO must build a strong reputation and brand awareness through partnering with major players in the industry and through increasing number of endorsed bodies. Studies have shown that focusing on quality control for endorsement procedure is key, since reputation is the most valuable asset TPO possesses.

Finally, market attractiveness of TPO endorsements is affected by multiple factors and the interaction between industry players and consumers. To maximize potential the TPO must be seen as a trustworthy agent and must be able to increase level of public awareness about the controversial offerings regulations. In these circumstances TPO endorsement may act as a catalyst for opinion change and increased public acceptance. The impact may be limited in jurisdictions where provision of controversial offerings is monopolistic or underdeveloped. The existence of TPO providing an evaluative service of quality assurance is a step towards

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legitimization of industries offering a product with higher perceived level of ambiguity.

List of references

Agrawal J., K.W. 1995, "The Economic Worth of Celebrity Endorsers: An Event Study Analysis", Journal of Marketing, vol. 59, no. 3, pp. 56-62.

Boulding W., K.A. 1993, "A Consumer-Side Experimental Examination of. Signalling Theory", Journal of Consumer research, vol. 20, no. 1, pp. 111-23.

Dasgupta P. (ed) 1988, Trust as a Commodity, D. Gambetta edn, Basil Blackwell, Oxford. Dean D.H. 1999, "Brand Endorsement, Popularity, and Event Sponsorship as Advertising Cues

Affecting Consumer Pre-purchase Attitudes", Journal of Advertising, vol. 28, no. Fall, pp. 1-12.

Dean D.H., B.A. 2001, "Third Party Organization Endorsement of Products: An Advertising Cue Affecting Consumer Pre-purchase Evaluation of Goods and Services.", Journal of

Advertising, vol. 30, no. 4, pp. 41-57.

Deephouse D.L. 1996, "Does isomorphism legitimate", Academy of Management Journal, vol. 39, no. 4, pp. 1024-1039.

Dowling G., S.R. 1994, "A Model of Perceived Risk and Intended Risk-Handling Activity", Journal of Consumer Research, vol. 21, no. 6, pp. 119-134.

Dunham B. 2011, "The role for signaling theory and receiver psychology in marketing", Evolutionaкy Psychology in the Business Science Ed. Saad, G. Springer.

Eisenhardt K. 1989, "Building Theories From Case Study Research", The Academy of Management Review, vol. 14, no. 4, pp. 532.

Feng, J., Wang, K., Peracchio, L. 2008, "How Third-party Organization (TPO) Endorsement Advertising Works: Do Consumers Perceive TPO Endorsement As Signals of Quality?", Advances in Consumer Research, vol. 35, pp. 616-622.

Freiden J.B. 1984, "Advertising Spokesperson Effects: An Examination of Endorser Type and Gender on Two Audiences.", Journal of Advertising Research, vol. 24, no. 5, pp. 33-41. Friedman H., F.L. 1979, "Endorser Effectiveness by Product Type", Journal of Advertising

Research, vol. 19, no. 5, pp. 67-71.

Gruère G., R.S. 2007, "A review of international labeling policies of genetically modified food to evaluate India’s proposed rule", AgBioForum, vol. 10, no. 1, pp. 51-64.

Gruère G., R.S. 2001, "Pew Initiative on Food and Biotechnology", Public sentiment about genetically modified food, , pp. 3.

(34)

implied third-party endorsement. Jim and Lauri Grunig’s research: A supplement of pr reporter 8, 4 pp.", Jim and Lauri Grunig’s research: A supplement of pr reporter 17, 4 pp., vol. 17, no. May, pp. 4.

Hallahan K. 1999, "Seven Models of Framing: Implication for Public Relations", Journal of Public Relations Research, vol. 11, no. 3, pp. 205-42.

Kahle L., H.P. 1985, "Physical attractiveness of the celebrity endorser: A social adaptation perspective", Journal of Consumer Research, vol. 11, no. 4, pp. 954-961.

Kamins M. 1989, "Celebrity and non-celebrity advertising in a two-sided context", Journal of Advertising Research, vol. 29, no. 3, pp. 34-42.

Kelman H. 1961, "Processes of opinion change", Public Opinion Quarterly., vol. 25, pp. 57-78. Kirmani A., R.A. 2000, "No pain, no gain: A critical review of the literature on signaling

unobservable product quality", Journal of Marketing, vol. 64, pp. 66-79.

McGinnis E., Ward C. D. 1980, "Better liked than right: trustworthiness and expertise as factors in credibility", Personality and Social Psychology Bulletin, vol. 6, no. 3, pp. 467-472. Meyer J., R.B. 1977, "Institutionalized Organizations: Formal Structure as Myth and Ceremony",

American Journal of Sociology, vol. 83, no. 2, pp. 340-363.

Montecalvo J. 2001, "The national organic program: An opportunity for industry.", Food Technology, vol. 55, no. 26.

Ohanian R. 1991, "The impact of celebrity spokespersons’ perceived image on intention to purchase", Journal of Advertising Research, vol. 31, no. 1, pp. 46-54.

Pallak M., Mueller M., Dollar M., Pallak J. 1972, "Effect of commitment on responsiveness to an extreme consonant communication.", Journal of Personality and Social Psychology, vol. 23, pp. 429-436.

Peterson R. A., Wilson W. R., Brown S.P. 1992, "Effects of Advertised Customer Satisfaction Claims on Consumer Attitudes and Purchase Intention", Journal of Advertising Research, vol. 32, no. March-Aptil, pp. 34-40.

Petty R. E., Cacioppo J. T. 1986, "Central and peripheral routes to attitude change." in Communication and persuasion, New York: Springer-Verlag.

Petty R. E., Cacioppo J. T. 1979, "Issue involvement can increase or decrease persuasion by enhancing message-relevant cognitive responses

", Journal of Personality and Social Psychology, vol. 37, pp. 1915-1926.

Pfeffer J., Salancik G. R. 1978, The External Control of Organizations: A Resource Dependence Perspective.

Raab C., G.D. 2003, "Labeling Genetically Engineered Food: The Consumer’s Right to Know?", AgBioForum, vol. 6, no. 7, pp. 155-161.

Sherif C. W., Merrilea K., Rodgers H. L., Sarup G., Tittler B. 1973, "Personal involvement, social judgment and action", Journal of Personality and Social Psychology, vol. 27, pp. 311-328.

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State of Colorado 2012, Colorado Limited Gaming Act, 12-47.1-102, Division of Gaming, Colorado, USA.

Swartz T. A. 1984, "Relationship between source expertise and source similarity in an advertising context", Journal of Advertising, vol. 13, no. 2, pp. 49-55.

The Mellman Group and Public Opinion Strategies 2001, Public sentiment about genetically modified food, Pew Initiative on Food and Biotechnology.

Wang A. 2005, "Integrating and Comparing Other’s Opinions: The Effects of Third-Party Endorsements on Online Purchasing", Journal of Website Promotion, vol. 1, no. 1, pp. 105-129.

West P.M., B.S.M. 1998, "Integrating multiple opinions: The role of aspiration level on consumer response to critic consensus.", Journal of Consumer research, vol. 25, no. 6, pp. 38-51. Wigblad R. 1997, The map of scientific relationships:an introduction to the jungle of social

science methodology, Lund.

Woodside A.G., D.J.W. 1974, "Effects of salesman similarity and expertise on consumer purchasing behavior", The Journal of Marketing Research, vol. 11, pp. 198-202.

Yin R.K. (ed) 2003, Case study research: Design and methods, 3rd edn, Thousand Oaks, CA: Sage.

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Appendix 1 Interview Guide Formal Procedure

Poker industry general:

1. How would you describe development in the poker industry over recent years? 2. How would you evaluate the role of regulations in the poker industry?

3. Which type of risk is involved within the poker offering?

4. Are you aware that FIDPA is presenting itself as a regulatory body in the poker industry who can provide quality assurance?

5. Which other organizations are governing the poker industry?

6. How do you evaluate expertise and trustworthiness of governing bodies of the poker industry?

7. What does quality level mean to the poker industry?

8. Is there a sense in having a Third-party organization is an independent organization providing support and information for the global poker industry and its players?

9. How do you evaluate the importance of having an independent expert opinion for quality standards in the poker industry?

Public awareness:

10. Which standards are you aware of for poker rulings?

11. What role do you see FIDPA is playing in educating and enhancing public awareness? 12. To what extent do you think customers are aware of poker regulations?

13. To what extent do you believe there is a public acceptance of the poker industry? 14. Who can generate the most opinion change towards poker in your view?

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Implied effects of endorsement:

15. To which extent could a TPO endorsement enhance profitability parameters of the offering?

16. To what extent does a TPO endorsement affect your view of controversial offering? 17. Would you be more likely to attend venues with have been endorsed over competitors? 18. Can spreading a standardized set of rules benefit the industry?

19. How does celebrity appeal affect casino brand awareness? What can that mean for profitability parameters?

20. How does a regulatory endorsement affect customer perception of venue’s credibility? 21. On what criteria do you base your decision of where to participate in poker events? 22. Does TPO endorsement provide additional benefits in your view?

Interoperability and the business issues:

23. How can a TPO endorsement be exploited by a marketing department of an endorsed venue?

24. How can a message containing a TPO endorsement be formulated to maximize customer reach?

25. Can it be seen as a signal of quality and safety for customers? 26. What do customers value the most?

27. Do you perceive FIDPA endorsement as a differentiator among competitors? 28. How often do you find there are disputes among customers?

29. To what extent does fairness in treatment towards customers matter?

30. Can having a standardized set of rules be seen as a solution for problems poker players encounter in terms of safety and quality of the offering? Is that relevant to their

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31. Does a TPO endorsement appeal to customers vary amongst different customer groups? 32. Do you foresee any benefits and/or issues for your organization as a result of being

regulated by FIDPA?

33. Specifically, what level of oversights and evaluative efforts will need to be made by FIDPA and how will this fit into your operations?

The market appeal of regulatory endorsements for controversailofferings - evidence from the poker industry.